Further BEPS guidance on Permanent Establishments

Mar 26, 2018

The OECD has just published a report entitled Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7).

According to the OECD, the additional guidance sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to Permanent Establishments (PEs) in accordance with applicable treaty provisions.  It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.